Justia U.S. 8th Circuit Court of Appeals Opinion Summaries

Rock Dental Arkansas PLLC and Rock Dental Missouri LLC (Rock Dental) operate dental clinics in Arkansas and Missouri. After Rock Dental’s insurer, Cincinnati Insurance Company (Cincinnati), denied coverage for Rock Dental’s claims for losses related to the COVID-19 pandemic, Rock Dental sued for breach of contract. The district court granted Cincinnati’s motion to dismiss for failure to state a claim.   The Eighth Circuit affirmed. The court explained that Rock Dental has failed to plausibly allege that COVID-19 physically damaged its properties or that removal of any virus from its properties was required. Further, Rock Dental has not shown that it is entitled to coverage under the Civil Authority Coverage. The court explained that coverage requires allegations of physical loss of or damage to properties other than Rock Dental’s clinics. Rock Dental’s complaint contains no such allegations. View "Rock Dental Arkansas PLLC v. Cincinnati Insurance Company" on Justia Law

Defendant was convicted of possession of a firearm by a felon in violation of 18 U.S.C. Section 922(g)(1). He appealed the district court’s denial of his motion to suppress, two additional evidentiary rulings, and the application of a sentencing enhancement under U.S.S.G. Section 2K2.1(a)(3).   The Eighth Circuit affirmed. The court first concluded that the officers had probable cause to arrest Richardson because the totality of the circumstances at the time of the arrest was sufficient to lead a reasonable person to believe that Defendant committed the offense of indecent exposure.   Further, the court concluded that the officers properly searched Defendant’s person and his car after he was arrested. The search of Defendant’s person was a proper search incident to arrest. The search of the CR-V was a proper probationary search because Defendant was subject to a probationary search condition and there was reasonable suspicion to believe that he possessed firearms based on the pistol magazine found in his pocket or that he violated the law by committing the offense of indecent exposure, both of which were prohibited by his probation conditions.   Moreover, the court held that the district court did not abuse its discretion in allowing the Government to introduce evidence about Defendant’s six prior convictions. Contrary to Defendant’s claim, the probative value of the evidence of his prior convictions was not substantially outweighed by the risk of unfair prejudice. Finally, the court explained it need not decide whether North Dakota robbery qualifies as a crime of violence because any alleged error was harmless. View "United States v. LaSamuel Richardson, III" on Justia Law

After voluntarily leaving his job due to back problems, Plaintiff applied for disability insurance benefits. The Social Security Administration found that he was not disabled and denied his application. Plaintiff sought judicial review and the district court1 affirmed. He appealed, arguing that the agency’s decision was not supported by substantial evidence.   The Eighth Circuit affirmed, explaining that when reviewing the denial of disability insurance benefits, the court decides whether the findings are supported by substantial evidence on the record as a whole. Here, Plaintiff claims that his treating physician’s opinion was entitled to deference. However, the court explained, that under the current regulations, however, treating physicians are not entitled to special deference. And although Plaintiff may disagree with the ALJ’s conclusion, it is supported by substantial evidence on the record as a whole. View "Jason Bowers v. Kilolo Kijakazi" on Justia Law

Defendant and the government reached a binding plea agreement whereby Defendant would plead guilty to transportation of a minor in violation of 18 U.S.C. Section 2423(a) and receive a below-guideline sentence of 150 months. At a change-of-plea hearing in March, the district court rejected the plea agreement. At the end of the second hearing, the district court accepted Defendant’s guilty plea. The district court imposed a sentence of life without the possibility of parole.   Defendant appealed arguing that the district court participated in plea negotiations in violation of Rule 11(c)(1) of the Federal Rules of Criminal Procedure, requiring vacatur of his conviction and sentence. The Eighth Circuit affirmed the district court’s order.   The court explained that Defendant waived “all rights to appeal or collaterally attack . . . [his] conviction or sentence [and] all non-jurisdictional issues.” Because Defendant’s appeal requests vacatur of his conviction and sentence, it falls within the scope of the waiver. However, a violation of Rule 11(c)(1) is appealable unless the defendant specifically waives “an appeal challenging the voluntariness of his plea.” Here, Defendant did not waive his right to appeal, thus the court wrote that Defendant must show that the district court’s error affected his substantial rights. The court explained that although at least one factor favors Defendant, the particular facts and circumstances in the entire record here do not show that the Rule 11 violation affected Defendant’s substantial rights. View "United States v. Douglas Schneider" on Justia Law

Plaintiffs appealed the district court’s grant of summary judgment in favor of Safeco Insurance Company of Illinois (“Safeco”). The case involved a dispute over the applicability of an “other structure” exclusion in a homeowner’s policy when the building sustaining damage was “used in whole or in part for business.”   At issue is a loss caused by the failure of an in-floor radiant heat system in a pole barn that was occasionally used for business purposes. The Eighth Circuit affirmed the district court’s summary judgment ruling in favor of Defendants. The court concluded that the business use exclusion for other structures precludes coverage for the loss, there is no evidence of bad faith on the part of Safeco, and Safeco had no duty to advise Plaintiffs about coverage.   The court explained that Plaintiffs’ arguments seeking to engraft an additional requirement on the business use exclusion—that the structure be used for “actual business activity”— or that the limited coverage for business property located on the premises somehow changes or modifies the plain language of the business use exclusion are unavailing. Because the policy language is unambiguous and the exclusion is neither obscure nor unexpected, the reasonable expectations doctrine is inapplicable. Thus, Safeco did not breach the contract when it denied coverage.Further, the court held that there is no other evidence of bad faith in the investigation of this claim. Finally, there is no evidence in the record to support a claim that Plaintiff either relied on the agent to provide appropriate coverage or needed protection from any specific threat. View "Joseph Wobig v. Safeco Ins Co of Illinois" on Justia Law

Wagstaff & Cartmell, LLP (Wagstaff) filed a declaratory-judgment action against the Defendant-Attorney, seeking a declaration that Wagstaff owed nothing to Defendant for any work on a wrongful death lawsuit or, in the alternative, a determination of the amount it owed to Defendant.   Defendant filed counterclaims against Wagstaff, including a counterclaim under the theory of quantum meruit. The district court entered judgment in Wagstaff’s favor. On appeal, Defendant argued that the district court erred in (1) denying his motion to dismiss for lack of subject-matter jurisdiction (2) denying his motion for leave to dismiss counterclaims without prejudice and motions for leave to file his second amended answer (3) denying his motion to dismiss the declaratory-judgment action without prejudice under the abstention doctrine and motion to reconsider the denial of that dismissal motion and (4) denying, in part, his motion to alter or amend the judgment or, in the alternative, relief from judgment.The Eighth Circuit affirmed the district court’s ruling in Plaintiff’s favor. The court concluded that the district court did not abuse its discretion in denying Defendant’s motion to alter or amend the judgment or, in the alternative, relief from judgment. The court held that the district court reasonably interpreted Defendant’s response to Wagstaff’s third summary judgment motion as an abandonment of his quantum meruit claim. In addition, Defendant had not sustained his burden of proving that Wagstaff has engaged in misconduct that prevented him from fully and fairly presenting his case. View "Wagstaff & Cartmell, LLP v. Neal Lewis" on Justia Law

Plaintiff, an employee of the Department of Veterans Affairs, sued Denis McDonough, Secretary of the Department of Veterans Affairs, for disability discrimination. Plaintiff alleged three violations of the Rehabilitation Act: failure to accommodate; disability discrimination; and retaliation for requesting an accommodation. The district court granted summary judgment to Secretary McDonough.   The Eighth Circuit affirmed. The court wrote that Plaintiff’s requested accommodation was not required under the Rehabilitation Act because it would impose an undue hardship on the VAPD. The court explained that Plaintiff’s accommodations would have violated the VAPD’s collective bargaining agreement, which requires that “[s]cheduled off-tours shall be rotated fairly and equitably among affected employees, i.e., day/evening, day/night.” Plaintiff’s requested accommodations are therefore presumptively unreasonable.   Plaintiff further argued that his reassignment was not reasonable for two reasons. First, he claimed that day shifts were not the only form of requested relief; they were just one of many possible accommodations the VAPD could have made. But the record undermines his argument. Further, he also suggested that his reassignment constituted an adverse employment action, not a reasonable accommodation. The VAPD provided the only available reasonable accommodation—reassignment. The district court was therefore correct to grant summary judgment to Secretary McDonough on Plaintiff’s failure to accommodate claim.   Moreover, Plaintiff claimed the unusual nature of his hiring process proves that the real reason for his non-selection was disability discrimination. However, showing that an interview process is “unusual” is not sufficient to prove that an employer’s proffered reason is pretextual. View "Jesse LeBlanc v. Denis McDonough" on Justia Law

The United States Secretary of Labor (“Secretary”) sued Alpha & Omega USA, Inc., d/b/a Travelon Transportation and its owner (together “Travelon”) for violating the Fair Labor Standards Act (FLSA). The district court granted summary judgment in favor of the Secretary. Travelon appealed, arguing the district court erred in granting the Secretary’s motion.   The Eighth Circuit reversed the district court’s grant of summary judgment finding that there were genuine issues of material fact regarding whether an employment relationship existed between Travelon and its drivers. The court wrote that when an employment relationship is in question, many courts decide whether workers are independent contractors or employees by applying the multi-factor “economic realities” test. This test examines six factors regarding the economic realities of the working relationship.   The court explained that here, viewing the evidence in the light most favorable to Travelon, issues of material fact remain as to the working relationship between Travelon and its drivers. Specifically, Travelon has offered evidence from which a rational trier of fact could find the “control,” “profits and losses,” and “integral to business” factors weigh in favor of the drivers being independent contractors.   Further, while the Secretary has shown evidence supporting an employment relationship between Travelon and its drivers, Travelon has also shown evidence of an independent contractor relationship. These competing narratives must be resolved before the district court makes its legal conclusion as to whether an employment relationship existed between Travelon and its drivers. View "Martin Walsh v. Alpha & Omega USA, Inc." on Justia Law

Missouri challenged the Secretary of the Treasury’s implementation of the American Rescue Plan Act of 2021 (ARPA), Pub. L. No. 117-2, 135 Stat. 4. Missouri argues that the Secretary’s “erroneously broad interpretation” of a provision in ARPA—the “Offset Restriction”—is unconstitutional. The district court dismissed the case, finding that Missouri lacked standing and that Missouri’s claims were not ripe for adjudication.   On appeal, Missouri identifies five specific ways it has been injured: (1) the broad interpretation of the Offset Restriction punishes Missouri for exercising its constitutional right to set taxes; (2) the Secretary’s “embrace of the broad interpretation” has harmed Missouri’s interest in the offer Congress provided to the State; (3) Treasury’s regulations make ARPA’s requirement more onerous, leading to greater compliance costs; (4) under the broad interpretation, there is an increased chance Missouri will lose ARPA funds; and (5) under the pre-enforcement test, Missouri has alleged an intention to engage in conduct arguably affected with a constitutional interest, but proscribed by statute, with a credible threat of enforcement hanging over it.   The Eighth Circuit affirmed, finding that Missouri has not alleged an injury in fact. The court explained that Missouri has only alleged a “conjectural or hypothetical” injury, not one that is actual or imminent. It has also not alleged a future injury that is “certainly impending” or even likely to occur. Instead, Missouri asked the court to declare, in the abstract, what a statute does not mean. It asked the court to enjoin a hypothetical interpretation of the Offset Restriction that the Secretary has explicitly disclaimed, without alleging any concrete, imminent injury from the Secretary’s actual interpretation. View "State of Missouri v. Janet Yellen" on Justia Law

Defendant, in addition to her full-time position as a St. Paul police officer, was cross-deputized as a federal agent to investigate an interstate sex-trafficking scheme. Many were charged, but none were convicted. The attention soon turned to Defendant, who faced lawsuits from the people she came across during the investigation, including the Plaintiff in this matter.   Plaintiff became involved because of a dangerous encounter with a witness in the federal sex-trafficking investigation. That witness made a call to Defendant, falsely claiming that Plaintiff started the dispute. In Defendant’s affidavit supporting the criminal complaint against Plaintiff, she identified herself as an “FBI Task Force Officer / St Paul MN PD Officer.”  Plaintiff sought to recover on a wrongful-arrest theory against Defendant, whom she has sued in two different capacities: as a St. Paul police officer and as a deputized federal agent.   The district court granted Defendant’s motion for summary judgment on the ground that her actions arose under color of federal law. The Eighth Circuit affirmed, finding that without any actual or purported relationship between Defendant’s conduct and her duties as a police officer no section 1983 action is available.   The court wrote that at issue here is whether Defendant acted under color of state law when she allegedly lied to protect a federal witness while serving on a federal task force. The court explained that state law had nothing to do with “the nature and circumstances” of Defendant’s conduct. The court wrote that Defendant acted within the scope of her federal duties while dealing with the situation, and she referenced her federal-task-force role during her conversations with officers. View "Ifrah Yassin v. Heather Weyker" on Justia Law